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Sexually Offensive Comments Not Enough to Violate Title VII

Angel Rector was a nurse practitioner employed by Wexford Health Sources, Inc. The director of Nursing, Anitra Steckenrider, was accused of making frequent sexually offensive comments. Her office was right next door to Ms. Rector and thus she could overhear these remarks. Apparently, Ms. Steckenrider discussed her own sexual experiences, physical appearance, and sexual desires using explicit language and graphic sexual references.

Ms. Rector complained about the sexually offensive comments made by Ms. Steckenrider on many different occasions. No action was taken in response to her complaints. However, she purportedly had actions taken against her for the complaints such as being denied overtime, having a reimbursement payment delayed, and she was accused of being a “ringleader.”

A federal district court dismissed Ms. Rector’s case on summary judgment. First, the court did not find evidence that the sexually offensive comments were based on Ms. Rector’s sex. The comments made were to other women about men. Ms. Steckenrider did not display any hostility to women in the workplace nor were they degrading to women in general. Furthermore, the comments alleged were not sufficiently severe or pervasive to create a hostile work environment. Most of the comments were not made to Ms. Rector or directed at her. Finally, the court dismissed Ms. Rector’s retaliation claim because she could not have a reasonable belief that she was being sexually harassed.